Letters or Comments

The American Petroleum Institute (“API”) is pleased to provide comments to the Department of Commerce on the Request for Information (RFI) on the Impact of Federal Regulations on Domestic Manufacturing.

The American Petroleum Institute (API) strongly supports the Congressional Review Act disapproval resolution for the Bureau of Land Management’s (BLM) Resource Management Planning, also called BLM Planning 2.0.

The American Petroleum Institute along with the American Gas Association, the American Public Gas Association, and the Interstate Natural Gas Association of America submitted comments on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Interim Final Rule establishing for the first time Federal pipeline safety regulations for underground natural gas storage facilities (Interim Final Rule or IFR).

API filed comments on Monday, February 13, 2017, to EPA’s Proposed Implementation of the 2015 National Ambient Air Quality Standards for Ozone: Nonattainment Area Classifications and State Implementation Plan Requirements (81 Fed. Reg. 81,276 (Nov. 17, 2016)). API’s comments focus on how best EPA can facilitate a less burdensome transition between the 2008 and 2015 standards so states and businesses are not dealing with two sets of requirements and timetables simultaneously. Further, API urges EPA to utilize the full scope of its statutory authority to extend compliance flexibility to areas not presently attaining the 2008 standards. API comments also cover the complexities of attaining the stringent ozone standards given the scope of background ozone and the lack of currently available EPA tools for states to use in crafting successful State Implementation Plans.

American Petroleum Institute along with the American Gas Association, American Public Gas Association, American Public Power Association, Association of Pipe Lines, Edison Electric Institute, Electric Power Supply Association, Independent Petroleum Association of America, Interstate Natural Gas Association of America, Larger Public Power Council, National Hydropower Association, National Rural Electric Cooperatives Association, Natural Gas Supply Association, and the Nuclear Energy Institute sent a letter to President Trump urging the administration to promptly nominate candidates to fill FERC's three existing vacancies as quickly as possible so a quorum can be reconstituted without undue delay.

Western Energy Alliance, the Colorado Oil & Gas Association, and the Colorado Petroleum Council strongly support the use of the Congressional Review Act to overturn the Bureau of Land Management’s (BLM) Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule, otherwise known as BLM’s methane rule.

On January 31, 2017, API President and CEO Jack Gerard sent this letter to House leaders Speaker Paul Ryan and Democratic Leader Nancy Pelosi. The American Petroleum Institute strongly supports H.J. Res. 36, providing for congressional disapproval under the Congressional Review Act (CRA) of the Department of Interior’s “Methane and Waste Prevention” rule that went into effect in the final days of the Obama administration. This redundant and technically flawed rule will further impede oil and natural gas production on federal land, which already has been declining – down 18 percent from 2010 to 2015. The rule is a step backwards for U.S. energy policy and all Americans who benefit from domestic energy production. As such, it is important that the House support the disapproval resolution so that the United States may harness the increased economic opportunity and enhanced national security that the nation’s abundant federal resources can provide.

API and its members believe in the importance of continued access to energy and other resources for safe and responsible development. We strongly urge Congress to re-examine the role and purpose of the Antiquities Act with a focus on the economic consequences to the affected states and communities, and to provide Congress and the affected states where the new national monuments are proposed a voice in these decisions.